Civil Penalties (TSCA PBT Enforcement)

TSCA violations, including non-compliance with PBT restrictions, can result in civil penalties up to $51,489 per day per violation (2024 inflation-adjusted maximum under 40 CFR 19.4). EPA has authority to inspect facilities, request compliance records, and initiate enforcement actions. Criminal penalties may apply for knowing or willful violations.

TSCA § 16; 40 CFR 19.4; EPA Enforcement and Compliance Assurance.

Civil penalties create strong financial incentives for compliance. The per-day, per-violation structure means penalties accumulate rapidly for ongoing non-compliance. Companies should ensure proactive compliance programs, maintain audit-ready documentation, and respond promptly to EPA information requests.

A manufacturer continues distributing PIP (3:1)-containing articles after the October 2026 prohibition date without qualifying for an exclusion. EPA issues a penalty of $51,489 per day for each day of continued distribution, plus additional penalties for failure to maintain required recordkeeping.